Jagannatha Shetty, J.—Since common order is challenged in these two petitions, they shall stand disposed of by this order.

2. The order challenged herein is an order made by the Commissioner of Income Tax under Section 264 of the Income Tax Act, 1961 (the Act). By the said order, the Commissioner dismissed the two revision petitions preferred by the petitioner against the levy of interest under Section 215 of the Act for the assessment years 1967-68 and 1968-69.

3. The facts, which are not now in dispute, may briefly be stated. The petitioner filed his estimate of advance tax payable by him on March 15, 1967, for the year 1967-68 and on March 15, 1968, for the year 1968-69. In the estimates he did not include the income of his minor sons. It is not disputed that the said income is to be assessed in the hands of the petitioner. It was not for the first time that he made such estimates. Even for the year 1962-63 he did the same thing. The authority said that the minors' income should be assessed in his hands. Ultimately, the matter came by way of reference to this court. This court upheld the action taken by the authorities in the case. The appeal preferred by the petitioner again